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Where was the Ethics?: Cheating Scandal Proves Good Example of Compliance Hot Spot.

Earlier this month 35 teachers, administrators and a superintendent in the Atlanta Public school system turned themselves in to the police. The teachers were accused of erasing and changing standardized test answers to improve scores. The motive was said to be federal funding and teacher bonuses for elevated student testing scores.

As the Project Post-Gazette lays out the framework for implementing a Compliance and Ethics (C&E) Program within organizations in this issue, one of the first areas in implementing a framework for a solid C&E program is starting with a risk assessment to determine hot spots for possible wrongdoing in the environment.

As the plot unfolded, it was clear the basics for a C&E program were not put into place in the Atlantic public school system. Well educated people fell under the spell of gain faced with the temptation of defrauding a system that was without a system to 1) Prevent wrong doing and 2) Detect wrong doing.

The teachers and administrators involved including a former Atlanta School Superintendent were caught due to the simple application of mathematical analysis when a local newspaper suggested that the recent increases in student test scores were statistically improbable. As the investigative reporting uncovered the scandal that went all the way to the top of the Atlanta Public School System, the outcome of the cheating scandal was revealed that the improved scores provided several school system administrators with additional bonuses and funds. For one of the administrator’s involvement in the scandal, she could be facing a total of 40 years if convicted on all counts.

Were the monies received worth the now possible jail time, and the tarnishing of a public school system official’s over 20 year long career? A sound compliance and ethics program could have provided the education and controls necessary to possibly prevent this scandal; however, this fact will never be known given that the scandal is a reality and under investigation.

After being caught, and too late, C&E steps are now being put into place in this school system:

1) Mandatory Annual Ethics Training

2) Testing Protocols

3) Triggers for possible Fraud

4) Ethics Expectations

One would now expect to see a causal link between the offering of bonuses and the possible temptation to manipulate the system in order to maximize the bonus schedule. While these may seem to be a bit far-fetched at first, once such a scandal has occurred many look back and ask, “why was not the link or possibility considered?” These are the basis for a sound C&E program where causal links can be investigated without the casting of blame or indication of wrong-doing without evidence.